Compliance officers at ADGM-regulated firms have had a busy year. Between new circulars, amended rulebooks, and the FSRA’s continued push to align with international standards, keeping your obligation register current has never been more demanding.
This post covers the material changes from the past year, what they mean for your firm, and what to watch in the months ahead.
What Changed
AML Framework Updates
The FSRA issued updated guidance on customer due diligence requirements under the Anti-Money Laundering and Sanctions Rules. The key changes affect:
- Enhanced due diligence thresholds for high-risk customers — the criteria for triggering EDD have been clarified, reducing ambiguity around “beneficial ownership complexity”
- Ongoing monitoring obligations — frequency requirements have been made more explicit for different customer risk categories
- Record-keeping periods — alignment with FATF recommendations extended the standard retention period for certain transaction records
If you haven’t updated your CDD procedures since the guidance was issued, this is worth reviewing with your MLRO.
Conduct of Business Rulebook (COBS)
Several conduct obligations were updated as part of the FSRA’s periodic review cycle:
- New requirements around appropriateness assessments for non-advised sales of complex instruments
- Clarification on best execution obligations for firms operating in multiple venues
- Updated client categorisation guidance, particularly around professional client opt-down procedures
The COBS changes are detailed — if you’re a Category 2 firm with retail-facing operations, the appropriateness assessment changes deserve a close read.
Market Infrastructure Updates
The ADGM Financial Services and Markets Regulations saw technical amendments related to market infrastructure oversight. These are largely relevant to Category 1 banks and recognised investment exchanges, but firms that use third-party execution venues should check whether any counterparty infrastructure changes affect their own obligations.
What It Means for Your Firm
The pattern across this year’s regulatory activity is consistent with what we’ve seen over the past few years: the FSRA is moving towards more specificity and less reliance on principles-based interpretation.
For compliance officers, this is both good and bad news.
Good news: Clearer rules mean less judgment call. When the CDD threshold is specified, you don’t have to defend your interpretation as much.
Bad news: The specificity means more obligation lines to track. A vague principle can be satisfied by a well-designed programme. A specific rule requires documented evidence that the specific rule is met.
If your obligation register is still built on broad principles with generic controls mapped to them, now is the time to review whether your mapping captures the new specificity.
What to Watch in 2026
DIFC AI Regulation Influence
DIFC enacted Regulation 10 on autonomous and semi-autonomous systems in 2023. ADGM hasn’t moved yet, but the direction is clear: AI tools used in regulated activities will face scrutiny.
If you’re using AI tools — including tools like Seif — for compliance-relevant decisions, you should be building your documentation now. What model? What training data? What review process? How do you handle uncertain answers?
This isn’t about fear — it’s about being ready before the regulation arrives, not after.
Sustainability and ESG Obligations
The FSRA has signalled increased focus on sustainability-related disclosures. For asset managers and investment advisers, ESG-related obligations are likely to expand. Watch for consultation papers in the first half of 2026.
Ongoing AML/CFT Focus
ADGM remains a high-priority jurisdiction for international AML/CFT standards bodies. Expect continued FSRA focus on the quality of suspicious activity reporting, ongoing monitoring programmes, and correspondent banking relationships.
How Seif Can Help
The challenge with regulatory change isn’t reading the new rules — it’s mapping them against your existing obligations, identifying gaps, and updating your programme.
Seif’s change monitoring tracks ADGM regulatory updates as they happen, classifies the impact, and maps changes to your existing obligation register. When the AML guidance was updated, Seif identified which obligation lines were affected and surfaced the delta — so you know exactly what to review.
If you want to see how this works for your firm’s specific firm type and regulated activities, book a demo.
This post is based on publicly available ADGM/FSRA regulatory publications. It is not legal advice. For specific compliance guidance, consult a qualified compliance professional or legal adviser.